“final assessment order”

Assessment ProceduresSection 144CSection 144C4,041 judgments

The decision most relied on for final assessment order is Parashuram Pottery Works Co. Ltd. v. ITO (106 ITR 1), cited in 486 judgments on BharatTax.

Leading authorities on final assessment order

Parashuram Pottery Works Co. Ltd. v. ITO

106 ITR 1 · 1977 · Supreme Court

486

citing judgments

The principle of finality dictates that stale issues should not be reactivated, and lapse of time brings repose to judicial and quasi-judicial controversies. A Commissioner cannot substitute their judgment for the Assessing Officer's unless the assessment order is legally erroneous, not merely less elaborate, thus limiting revisionary powers under Section 263.

Commissioner of Income Tax v. Roca Bathroom Products (P) ltd.

445 ITR 537 · 2022 · High Court

269

citing judgments

The time limit for the Assessing Officer to pass a final assessment order under Section 144C(13) following directions from the Dispute Resolution Panel is determined by the specific provisions of Section 153, particularly Section 153(2A).

CIT v. G.M. Knitting Industries (P.) Ltd.

376 ITR 456 · 2015 · Supreme Court

221

citing judgments

The requirement to file a certificate or form (e.g., Form 10CCB, 10-IC) along with the return of income for claiming a deduction (e.g., under sections 80-IB, 115BAA) is directory regarding its timing. Such a deduction is allowable if the requisite form is filed before the final order of assessment, as procedural requirements should not override substantive benefits.

Sultana Begum v. Prem Chand Jain

259 ITR 449 · 2003 · Supreme Court

147

citing judgments

Section 144C(4) uses a non-obstante clause to expedite the final assessment order, requiring the Assessing Officer to pass it immediately upon acceptance or lack of objection to the TPO's order, irrespective of broader time limits under Section 153.

Vijay Television (P.) Ltd. v. DRP

369 ITR 113 · 2014 · High Court

140

citing judgments

Passing a final assessment order under Section 143(3) directly, without first issuing a draft assessment order under Section 144C(1) for an eligible assessee, constitutes a fundamental jurisdictional defect. This defect cannot be cured by a subsequent corrigendum, especially if issued beyond the prescribed period of limitation.

ESPN Star Sports Mauritius S.N.C. ET Compagnie v. Union of India

388 ITR 383 · 2016 · High Court

citing judgments

Failure to issue a draft assessment order under Section 144C(1) makes the final assessment order illegal and beyond jurisdiction. Non-compliance with Dispute Resolution Panel (DRP) directions renders the final assessment order bad in law.

Travancore Diagnostics P. Ltd. v. ACIT

390 ITR 167 · 2017 · High Court

citing judgments

Failure to issue notice under section 143(2) before finalizing a reassessment order under section 147 is a fatal jurisdictional error, and this defect cannot be cured by invoking section 292BB of the Income-tax Act. Consequently, such a reassessment order is not sustainable in law.

Addl. CIT v. Mukur Corporation

111 ITR 312 · 1978 · High Court

citing judgments

When setting aside an assessment under Section 263(1) and directing a fresh assessment, the Commissioner need not record final conclusions or express final opinions on controversial points. It also interprets 'prejudicial to the interests of the Revenue' as meaning the assessment order is not in accordance with law, leading to the non-realization of lawful revenue.

Judgments citing final assessment order

M/S. Hp Computing and Printing Systems India Private Limited, Bangalore vs. Assistant Commissioner of Income-Tax, Circle-3(1)(1), Bangalore

In the result, the appeal by the assessee is allowed

ITA 193/BANG/2022[2017-18]Status: DisposedITAT Bangalore22 Jul 2022AY 2017-18

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri Sharath Rao, CAFor Respondent: Shri Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru

Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144Section 234B

following grounds:- Grounds of Appeal S.No Tax Effect (in INR) 1. Assessment is bad in law and on facts The final assessment order dated 28 January 2022 passed by the National Faceless Assessment Centre, Delhi ('NFAC' or the 'AO') under section 143(3) r.w.s. 144C(3) read with section ... under section 234B of the Act c) Determining tax demand of INR 178,661,240 as per computation received along with the final assessment order for the subject assessment year Erroneous adjustment made with respect to provision for 3 2,833,389 gratuity 3.1 The Ld.AO erred in making

Cisco Systems Capital (India) Private Limited, Bengaluru vs. Joint Commissioner of Income Tax, Circle- 2(1)(1), Bangalore

In the result, the assessee’s appeal is partly allowed for statistical purposes

ITA 321/BANG/2022[2017-18]Status: DisposedITAT Bangalore21 Jul 2022AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Rajan Vora, A.RFor Respondent: Shri G. Manoj Kumar, D.R

Section 115JSection 142(1)Section 143(2)Section 143(3)Section 144C(5)

much after the judgement of in the case of Asea Brown Boveri Ltd (supa). Accordingly, the Tribunal has reversed the findings in the final assessment order dated November 24, 2017 and remanded the matter back to AO's file for fresh adjudication with a direction to the assessee to produce ... hereby reversed as these are not in accordance with law. 7. Be it as it may, as at page 18 of the final assessment order for the AY 2011-12, the AO records that the assessee was asked to produce copies of agreements and that the assessee had only produced

M/S. Sap Labs India Private Limited, Bangalore vs. Joint Commissioner of Income Tax, Special Range-6, Bangalore

In the result, the appeal filed by the assessee stands partly allowed

ITA 606/BANG/2021[2008-09]Status: DisposedITAT Bangalore21 Jul 2022AY 2008-09

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Appeal No. Appellant Respondent Year M/S. Sap Labs India Pvt. Ltd., No. 138, Export It(Tp)A No. Promotion Industrial 2008-09 606/Bang/2021 Park, Whitefield, Bangalore – 560 066. Pan: Aafcs3649P The Joint M/S. Sap Labs India Commissioner Of Pvt. Ltd. Income Tax, (Successor To M/S. Special Range – 6, Success Factors Bangalore. Business Solutions It(Tp)A No. India Pvt. Ltd.), 2015-16 2510/Bang/2019 No. 138, Export Promotion Industrial Park, Whitefield, Bangalore – 560 066. Pan: Aafcs3649P

For Appellant: Shri Aliasger Rampurwala, CA

Section 3(1)(b)

PILLAI, JUDICIAL MEMBER Present appeals has been filed by assessee against the order of Ld.CIT(A) dated 10/12/2019 for A.Y. 2008-09 and final assessment order dated 17/10/2019 passed by Ld.JCIT, Special Range – 6 for A.Y. 2015-16 on following grounds of appeal. Page 2 IT(TP)A Nos. 606/Bang/2021

On Semiconductor Technology India Private Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, the additional ground raised by the assessee is allowed for statistical purposes

ITA 291/BANG/2021[2016-17]Status: DisposedITAT Bangalore21 Jul 2022AY 2016-17

For Appellant: Sri.Chavali Narayan, CAFor Respondent: Dr.Manjunath Karkihalli, CIT-DR

Section 143(2)Section 143(3)Section 92C

Hearing : 12.07.2022 O R D E R Per George George K, JM : This appeal at the instance of the assessee is directed against final assessment order dated 30.04.2021 passed u/s 143(3) r.w.s. 144C(13) of the I.T.Act. The relevant assessment year is 2016-2017. 2. The issues raised ... reduced to Rs.4,01,39,320 (instead of Rs.4,58,98,195 proposed by the TPO). The adjustment was incorporated in the final assessment order dated 13.04.2021. 4. Aggrieved by the final assessment order, the assessee has filed the present appeal before the Tribunal. We shall briefly describe

M/S. Success Factors Business Solutions India Private Limited (Now Merged With Sap Labs India Private Limited), Bangalore vs. Joint Commissioner of Income Tax, Special Range - 6, Bangalore

In the result, the appeal filed by the assessee stands partly allowed

ITA 2510/BANG/2019[2015-16]Status: DisposedITAT Bangalore21 Jul 2022AY 2015-16

For Appellant: Shri Aliasger Rampurwala, CA

Section 3(1)(b)

M/S Denso Kirloskar Industries Pvt.Ltd., Bangalore vs. Assistant Commissioner of Income-Tax, Bangalore

In the result, the appeal by the assessee is partly allowed

ITA 73/BANG/2017[2012-13]Status: DisposedITAT Bangalore20 Jul 2022AY 2012-13

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri V.S. Chakrapani, CIT(DR)(ITAT), Bengaluru

Date of hearing : 23.06.2022 Date of Pronouncement : 20.07.2022 O R D E R Per Padmavathy S., Accountant Member This appeal is against the final assessment order dated 10.11.2016 passed by the Assessing Officer for the AY 2012-13. 2. The assessee is a company engaged in the business of manufacture ... incorporating the above TP adjustment. The DRP rejected the objections of the assessee and upheld the TP adjustment. Consequently, the final assessment order was passed sustaining the TP adjustment of Rs.56,87,323. Aggrieved, the assessee is in appeal before the Tribunal. 4. Though various grounds of appeal are raised

ACIT Cir 1, Thane vs. Lanxess India P.Ltd, Thane

ITA 2788/MUM/2014[2009-10]Status: DisposedITAT Mumbai18 Jul 2022AY 2009-10

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2009-10 Lanxess India Private Limited, Asst. Commissioner Of Income-Tax, Lanxess House, Plot No. 162-164, Circle 1, Road No. 27, Wagle Estate, Opp. Iti Vs. 6Th Floor, Asher It Park, Road No. College, Midc, 16-Z, Wagle Industrial Estate, Thane-(West)-400604. Thane. Pan No. Aaccb 3880 A Appellant Respondent Assessment Year: 2009-10 Asst. Commissioner Of Income-Tax, Lanxess India Private Limited, Circle 1, Lanxess House, Plot No. 162-164, 6Th Floor, Asher It Park, Road No. 16- Vs. Road No. 27, Wagle Estate, Opp. Iti Z, Wagle Industrial Estate, College, Midc, Thane. Thane-(West)-400604 Pan No. Aaccb 3880 A Appellant Respondent

For Appellant: Mr. Pratik Shah/For Respondent: Mr. V.K. Agarwal, CIT-DR

Section 143(3)Section 144C(13)

assessee and the Revenue are These cross appeals by the assessee and the These cross appeals by the assessee and the directed against final assessment order dated 26/02/2014 passed directed against final assessment order dated 26/02/2014 passed directed against final assessment order dated 26/02/2014 passed by the Assistant Commissioner ... proceedings consequent to Act, 1961 (Act') and all proceedings consequent to such draft such draft assessment order including final assessment order including final assessment order passed u/s assessment order passed u/s 143(3) read with 144C(13) of the Act dated 26 February 2014 are 143(3) read with 144C

Lanxess India P.Ltd, Thane vs. Asst CIT Cir 1, Thane

ITA 2628/MUM/2014[2009-10]Status: DisposedITAT Mumbai18 Jul 2022AY 2009-10

For Appellant: Mr. Pratik Shah/For Respondent: Mr. V.K. Agarwal, CIT-DR

Section 143(3)Section 144C(13)

M/S Te Connectivity India Pvt Ltd, Bengaluru vs. Deputy Commissioner of Income Tax, Ltu, Circle-1, Bengaluru

In the result, the appeal by the assessee is partly allowed

ITA 2680/BANG/2017[2013-14]Status: DisposedITAT Bangalore18 Jul 2022AY 2013-14

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

For Appellant: Shri Sumeet Khurana, CAFor Respondent: Shri V.S. Chakrapani, CIT(DR)(ITAT), Bengaluru

Section 143(2)Section 143(3)Section 40Section 92

Date of hearing : 23.06.2022 Date of Pronouncement : 18.07.2022 O R D E R Per Padmavathy S., Accountant Member This appeal is against the final assessment order of the AO passed u/s. 143(3) r.w.s. 144C of the Income-tax Act, 1961 [the Act] dated 9.10.2017 in pursuance ... corporate tax additions/disallowances made IT(TP)A No.2680/Bang/2017 Page 4 of 50 by the AO. In pursuance thereof, the AO passed the final assessment order. Aggrieved, the assessee is in appeal before the Tribunal. 7. The assessee has raised 32 grounds. (i) Ground No. 1, 2 & 3 are general grounds

M/S. Sprinklr India Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-6(1)(2), Bengaluru

In the result, the appeal filed by the assessee is partly allowed and the stay application filed by the assessee is dismissed

ITA 250/BANG/2022[2017-18]Status: DisposedITAT Bangalore15 Jul 2022AY 2017-18

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.250/Bang/2022 : Asst.Year 2017-2018 & Sa No.22/Bang/2022 M/S.Sprinklr India Private Limited The Deputy Commissioner Of 3Rd Floor, East Wing Building Income-Tax, Circle 6(1)(2) V. Bengaluru. No.3, Block B, Divyashree 770 Town Centre, Off Hal Airport Road, Yamlur P.O. Bengaluru – 560 037. Pan : Aaqcs9370N. (Appellant/Applicant) (Respondent) Appellant By : Sri.Tata Krishna, Advocate Respondent By : Sri.Sumeer Singh Meena, Cit-Dr Date Of Pronouncement : 15.07.2022 Date Of Hearing : 13.07.2022 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 18.02.2022. The Relevant Assessment Year Is 2017-2018. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Wholly Owned Subsidiary Of Sprinklr Us. It Provides Software Development Services To Its Parent Company. For The Assessment Year 2017-2018, The Return Of Income Was Filed On 31.10.2017 Declaring Total Income Of Rs.24,99,66,540. The Assessment Was Selected For Scrutiny & Notice U/S 143(2) Of The I.T.Act Was Issued. During The 2 It(Tp)A No.250/Bang/2022 & Sa 22/B/2022. M/S.Sprinklr India Private Limited. Course Of Assessment Proceedings, The Matter Was Referred To The Transfer Pricing Officer (Tpo) To Determine The Arm’S Length Price (Alp) Of The International Transaction Undertaken By The Assessee With Its Associated Enterprises (Aes). The Tpo Vide His Order U/S 92Ca Of The I.T.Act Dated 27.01.2021 Determined The Tp Adjustment Of Rs.12,63,71,153. The Details Of The Tp Adjustment Made By The Tpo Reads As Follows:-

For Appellant: Sri.Tata Krishna, AdvocateFor Respondent: Sri.Sumeer Singh Meena, CIT-DR

Section 143(2)Section 92C

Hearing : 13.07.2022 O R D E R Per George George K, JM : This appeal at the instance of the assessee is directed against final assessment order dated 18.02.2022. The relevant assessment year is 2017-2018. 2. The brief facts of the case are as follows: The assessee is a wholly ... raised by the assessee. However, the DRP in its order directed the TPO to verify certain issues. Pursuant to the DRP’s directions, final assessment order was passed on 18.02.2022 incorporating the same transfer pricing adjustment proposed in the TPO’s order. 5. Aggrieved by the final assessment order

Epson India Private Limited, Ulsoor vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

In the result, the appeal filed by the assessee stands partly allowed

ITA 206/BANG/2021[2016-17]Status: DisposedITAT Bangalore14 Jul 2022AY 2016-17

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 206/Bang/2021 Assessment Year : 2016-17 M/S. Epson India Pvt. Ltd., The Deputy 12Th Floor, The Milenia, Commissioner Of Tower A, Income Tax, No. 1,Murphy Road, Circle 2 (1)(1), Ulsoor, Vs. Bangalore. Bangalore – 560 008. Pan: Aaace7858F Appellant Respondent : Shri Padamchand Khincha, Assessee By Ca : Dr. Manjunath Karkihalli, Revenue By Cit Dr Date Of Hearing : 15-06-2022 Date Of Pronouncement : 14-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 25/03/2021 Passed By National E-Assessment Centre, Delhi For A.Y. 2016-17 On Following Grounds Of Appeal: “General Ground 1. The Orders Passed By Learned Additional / Joint / Deputy / Assistant Commissioner Of Income Tax / Income- Tax Officer, National E-Assessment Centre (Hereinafter Referred As "Ao" For Brevity), Learned Deputy Commissioner Of Income Tax (Tp) — 1(2)(1), Bangalore (Hereinafter Referred As "Tpo" For Brevity) & The Honourable Drp-1

For Respondent: Shri Padamchand Khincha

Date of Pronouncement : 14-07-2022 ORDER PER BEENA PILLAI, JUDICIAL MEMBER Present appeal is filed by assessee against the final assessment order dated 25/03/2021 passed by National e-assessment Centre, Delhi for A.Y. 2016-17 on following grounds of appeal: “GENERAL GROUND 1. The Orders passed by learned Additional

Mutha Engineering Pvt. Ltd., Mumbai vs. The Dy. Commissioner of Income Tax Circle 4 (2)(2), Mumbai

In the result, appeal by the assessee is partly allowed in terms indicated above

ITA 7226/MUM/2018[2014-15]Status: DisposedITAT Mumbai13 Jul 2022AY 2014-15

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri G.P. MehtaFor Respondent: Shri Tejinder Pal Singh Anand

Section 143(3)Section 144C(5)Section 40ASection 92B

13/07/2022 O R D E R PER SANDEEP SINGH KARHAIL, J.M. The present appeal has been filed by the assessee challenging the impugned final assessment order dated 23/10/2018, passed by the Assessing Officer u/s 143(3) r/w section 144C(5) of the Income Tax Act, 1961 (‘the Act’) pursuant

M/S Marlabs Innovations Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-4(1)(2), Bangalore

In the result, the appeal filed by the assessee stands allowed

ITA 457/BANG/2019[2011-12]Status: DisposedITAT Bangalore13 Jul 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2011-12 M/S. Marlabs Innovations Pvt. Ltd., (Successor Of Marlabs Software Pvt. Ltd.), The Deputy 14Th Floor, Citrine Block-4, Commissioner Of Bagmane World Technology Income Tax, Centre, Circle – 4(1)(2), Marathalli Outer Ring Vs. Bangalore. Road, Mahadevapura, Bengaluru – 560 048. Pan: Aaccm6627Q Appellant Respondent Assessee By : Shri L. Bharath, Ca Revenue By : Shri Arun Kumar, Cit Dr Date Of Hearing : 23-06-2022 Date Of Pronouncement : 13-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Order Dated 28/12/2018 Passed By Ld.Dcit, Circle – 4(1)(2), Bangalore For A.Y. 2011-12. 2. The Assessee Has Raised Various Issues On The Transfer Pricing Adjustment Made In Respect Of The International Transactions Between Assessee & Its Ae.

For Appellant: Shri L. Bharath, CAFor Respondent: Shri Arun Kumar, CIT DR

Section 142(1)Section 143(2)Section 2(31)Section 394

which is clear from the cause title of the DRP directions. On receipt of the DRP direction, the Ld.AO passed the final assessment order in the name of erstwhile company being Marlabs Software Pvt. Ltd. 9. The following chart will explain the facts of the assessee’s case

M/S. Subex Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 6(1)(2), Bangalore

In the result, the appeal filed by the assessee stands partly allowed

ITA 2579/BANG/2019[2015-16]Status: DisposedITAT Bangalore11 Jul 2022AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 2579/Bang/2019 Assessment Year : 2015-16 M/S. Subex Ltd., The Deputy Rmz Ecoworld, Commissioner Of Outer Ring Road, Income Tax, Devarabisanahalli, Circle – 6(1)(2), Bangalore – 560 103. Vs. Bangalore. Pan: Aabcs9255R Appellant Respondent Assessee By : Shri Ajay Rotti, Ca : Shri Sumer Singh Meena, Revenue By Cit-Dr Date Of Hearing : 11-07-2022 Date Of Pronouncement : 11-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 23/10/2019 Passed By Ld.Dcit, Circle – 6(1)(2), Bangalore For A.Y. 2015-16 On Following Grounds Of Appeal: “The Grounds Stated Hereunder Are Independent Of & Without Prejudice To One Another. The Appellant Submits As Under: 1. Erroneous Transfer Pricing Adjustments Arising From Interest On Trade Receivables 1.1. The Deputy Commissioner Of Income Tax, Circle - 6(1)(2), Bangalore (Learned Assessing Officer' Or 'Ld. Ao') / Assistant Commissioner Of Income Tax, Transfer Pricing Circle - 1(3)(1) ('Learned Transfer Pricing Officer' Or 'Ld.

For Appellant: Shri Ajay Rotti, CA

Section 234ASection 234BSection 271(1)(c)

Date of Pronouncement : 11-07-2022 ORDER PER BEENA PILLAI, JUDICIAL MEMBER Present appeal is filed by assessee against the final assessment order dated 23/10/2019 passed by Ld.DCIT, Circle – 6(1)(2), Bangalore for A.Y. 2015-16 on following grounds of appeal: “The grounds stated hereunder are independent

Sigma Aldrich Chemicals Private Limited, Bangalore vs. DCIT, Bangalore

In the result, grounds 22 to 22

ITA 596/BANG/2016[2011-12]Status: DisposedITAT Bangalore11 Jul 2022AY 2011-12

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.418/Bang/2015 : Asst.Year 2010-2011 It(Tp)A No.596/Bang/2016 : Asst.Year 2011-2012 M/S.Sigma Aldrich Chemicals The Deputy Commissioner Of Private Limited, No.12, Income-Tax, Circle 6(1)(1) V. Bangalore. Bommasandra-Jagani Link Road, Bommasandra Industrial Area Bangalore – 560 100. Pan : Aahcs1882L. (Appellant) (Respondent) Appellant By : Sri.Tata Krishna, Advocate Respondent By : Sri.Sumer Singh Meena, Cit-Dr Date Of Pronouncement : 11.07.2022 Date Of Hearing : 07.07.2022 O R D E R Per George George K, Jm : These Appeals At The Instance Of The Assessee Are Directed Against Two Final Assessment Order Dated 19.01.2015 & 28.01.2016 For Assessment Years 2010-2011 & 2011- 2012, Respectively. Common Issues Are Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Of By This Consolidated Order.

For Appellant: Sri.Tata Krishna, AdvocateFor Respondent: Sri.Sumer Singh Meena, CIT-DR

Section 153Section 153BSection 92C

George George K, JM : These appeals at the instance of the assessee are directed against two final assessment order dated 19.01.2015 and 28.01.2016 for assessment years 2010-2011 and 2011- 2012, respectively. Common issues are raised in these appeals, hence, they were heard together and are being disposed ... reads as follows:- Corporate Tax Grounds: “11. 11.1 The learned AO erred in not considering partial credit for Advance Tax, while passing the final assessment order. The learned AO erred in granting incorrect advance tax amount of Rs.110,000,000/- as against claimed by the assessee amounting to Rs.110

Sigma Aldrich Chemicals Private Limited, Bangalore vs. DCIT, Bangalore

In the result, grounds 22 to 22

ITA 418/BANG/2015[2010-11]Status: DisposedITAT Bangalore11 Jul 2022AY 2010-11

For Appellant: Sri.Tata Krishna, AdvocateFor Respondent: Sri.Sumer Singh Meena, CIT-DR

Section 153Section 153BSection 92C

Accenture Solutions Pvt Ltd. (Asol) As A Successor to Accenture Serivces Pvt Ltd (Aspl), Mumbai vs. Dy CIT Circle- 14 (1)(1), Mumbai

ITA 8008/MUM/2019[2015-16]Status: DisposedITAT Mumbai07 Jul 2022AY 2015-16

Bench: Shri Baskaran Br & Shri Kuldip Singhassessment Year: 2015-16 M/S. Accenture Solutions The Dy. Commissioner O Pvt. Ltd. (‘Asol’), Income Tax, (As A Successor To Circle 14(1)(1), Accenture Services Pvt. 475, Aayakar Bhavan, Ltd. (‘Aspl’) Which Has M.K. Road, Merged Into Asol With An Mumbai - 400020 Effective Date Of 1 Vs. December 2016) Plant 3, Godrej & Boyce Complex, Phirojshah Nagar, Vikhroli West, Off L.B.S Marg, Mumbai – 400 079 Pan: Aacca8997K (Appellant) (Respondent)

For Appellant: Shri Percy J. Pardiwalla, A.RFor Respondent: Dr. Yogesh Kamat, D.R

Section 143Section 143(3)Section 144C(13)Section 92CSection 92C(3)

erred in law in incorporating the TP adjustment proposed in the TP order which is invalid and bad in law into the Final Assessment Order passed under section 143(3) read with section 144C (13) of the Act.” On the ground that additional ground sought to be raised is legal

Ntt Data Information Processing Services Private Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Circle - 3(1)(1), Bangalore

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 297/BANG/2021[2016-17]Status: DisposedITAT Bangalore07 Jul 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Chavali Narayan, A.RFor Respondent: Shri Manjunath Karkihalli, D.R

Section 143(3)

Date of Pronouncement : 07.07.2022 O R D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: This appeal by assessee is directed against the final assessment order passed by NFAC Delhi dated 30.4.2021 u/s 143(3) r.w.s. 144C(13) r.w.s. 144B of the Act. The assessee has raised following grounds of appeal ... return of income (ROI) has erroneously been omitted by the learned AO, although in the computation sheet of even date, attached to the final assessment order, assessable income has been computed after allowing deduction under section 10AA of the Act. 9. Other grounds 9.1 The learned AO has erred

Vena Energy Patan Power Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle- 2(2), Bangalore

In the result, the appeal is allowed in favour of the assessee

ITA 198/BANG/2021[2016-17]Status: DisposedITAT Bangalore07 Jul 2022AY 2016-17

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Smt. Susan Dolores George, CIT(OSD)(DR)

Section 115JSection 143(3)Section 40

Date of Pronouncement : 07.07.2022 O R D E R Per Padmavathy S., Accountant Member These are appeals by four different assessees against the final assessment order passed by the AO u/s. 143(3) r.w.s. 144C(13) of the IT(TP)A Nos.195 to 198/Bang/2021 Page 2 of 26 Income ... reduced the amount of disallowance to Rs.9,45,270. In pursuance of the directions of the DRP, the AO passed the final assessment order. Aggrieved, the assessee is in appeal before the Tribunal. TP adjustment towards interest on issue of NCD 5. During the year under consideration the assessee made

Vena Energy Mh Wind Power Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bangalore

In the result, the appeal is allowed in favour of the assessee

ITA 197/BANG/2021[2016-17]Status: DisposedITAT Bangalore07 Jul 2022AY 2016-17

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Smt. Susan Dolores George, CIT(OSD)(DR)

Section 115JSection 143(3)Section 40